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RICHARDSON v. COMMISSIONER

Docket Nos. 12252-97, 12253-97.

76 T.C.M. 845 (1998)

T.C. Memo. 1998-405

Donald C. Richardson and Rita M. Allaire v. Commissioner. Paige Communications Corporation of Louisiana v. Commissioner.

United States Tax Court.

Filed November 12, 1998.

Attorney(s) appearing for the Case

William A. Neilson and Joseph J. Ecuyer III, for the petitioners. Joseph Ineich, for the respondent.

MEMORANDUM OPINION

PANUTHOS, Chief Special Trial Judge:

This matter is before the Court on petitioners' motions for award of reasonable litigation and administrative costs under section 74301 and Rules 230, 231, and 232. These related cases have been consolidated for the purpose of considering these motions.

On March 13, 1997, respondent issued statutory notices of deficiency...

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